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BNPL Undisclosed Late Fees / Interest Charges

Buy-Now-Pay-Later provider charged late fees or interest not clearly disclosed at checkout, or applied fees retroactively.

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Legal Basis in the Philippines

  • RA 3765 (Truth in Lending Act) — all fees and charges must be disclosed before the transaction
  • BSP Circular 1133 (2021) — caps on interest and fees apply to BNPL products supervised by BSP
  • RA 7394 §52 (Consumer Act) — price labeling requirements; undisclosed surcharges are unlawful

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